Low Carbon Fuels Strategy

April 2022 Low Carbon Fuels Strategy: Call for Ideas Response from Railway Industry Association 1.

INTRODUCTION

1.1

The Railway Industry Association (RIA) is pleased to respond to the DfT Call for Ideas on a Low Carbon Fuels Strategy. No part of this response is confidential.

2.

BACKGROUND TO RIA

2.1

RIA is the voice of the UK rail supply community; the national trade association for UK-based suppliers to the railway industry. Established over 140 years ago, RIA has over 300 member companies from across the supply chain, over 60% of which are small or medium sized enterprises (SMEs). Our member companies represent a large proportion of the rail industry by turnover, reflect a great diversity of disciplines within the sector and cover the lengths and breadths of the UK.

3.

SUMMARY AND GENERAL COMMENTS

3.1

Rail is an inherently energy efficient mode of surface transport due to its very low rolling resistance and greenhouse gas emissions from rail transport are small compared to other modes. However, it is still vitally important that rail decarbonises at pace to ensure it remains an attractive and environmentally advantageous mode of transport for the future. It is also imperative that rail decarbonisation is achieved in a way that does not pass on a significant cost to customers and in so doing create a modal shift away from rail towards less efficient road transport.

3.2

RIA supports the industry’s Traction Decarbonisation Network Strategy (TDNS) and the DfT’s Transport Decarbonisation Plan (TDP). The TDNS makes the case for widescale electrification of the GB rail network to achieve net-zero emissions, with hydrogen and battery as the preferred traction energy choice for passenger vehicles on lines which aren’t appropriate for overhead line electrification. The need to decarbonise heavy freight traffic (90% of rail freight is hauled by diesel traction currently) is a significant driver for electrification of secondary and freight routes as battery and hydrogen are not currently considered feasible alternatives and would require expensive new locomotives. It should be noted that the whilst the TDNS represents one route to achieving net zero, current plans for further electrification of the rail network fall far short of the TDNS ambition.

3.3

The LCF strategy needs to recognise that the GB railway is not unique in its amount of electrification and there are railways around the world, e.g., North America where the electrification rate is far lower than in the UK. Decarbonisation of rail is therefore a shared challenge, but unlike aviation and road transport the challenge is not necessarily a global one.

Understanding the trends and drivers in countries with shared challenges could help in shaping the strategy for rail specifically. It could also create export opportunities if the UK takes a leadership role.

1/7

3.4

The rail industry is rarely a technology leader – due to the comparatively low numbers of trains manufactured, rail engines are typically derived from genset and marine applications – therefore rail inherits the capabilities of these engines rather than driving their specification.

Therefore, for rail to make use of LCFs in combustion engines the availability and technology readiness of suitable engines needs to be properly considered. However, this opens up the scope for collaboration and aggregating demand across sectors. For fuel cell based LCFs there are fewer constraints on the available technologies that can be adapted for rail applications.

3.5

The use of multi-mode trains which can make use of electrification where this exists and switch over to onboard energy storage for running off wires is seen by the industry as a possible transitional technology until more of the GB network is electrified.

3.6

The choice of traction energy source for off-wire running is therefore important and whilst there is a clear industry preference for batteries and hydrogen to fulfil this role for passenger trains there is sustained interest in the use of LCFs too. LCF’s are particularly attractive to the rail freight sector as battery and hydrogen are not considered feasible for long distance ‘off wire’ and new multi-mode locomotives would be required. Whereas LCF’s offer a ‘drop-in’ fuel solution for existing diesel freight locomotives, many of which have a significant remaining life.

The LCF strategy will need to ‘speak’ to the rail industry, so that going forward the industry is able to make more informed choices as to which LCFs are the most likely candidates for use as a transitional technology to net zero.

Chapter 1 – Introduction 4.

QUESTION) How can the low carbon fuels strategy best improve certainty about the deployment of low carbon fuels to support the decarbonisation of the transport sector and the growth of this industry in the UK?

4.1

From the railway industry perspective, the strategy needs to include realistic scenarios that provide the industry with greater clarity around the likely availability of low carbon fuels and the timeframes associated with this.

4.2

The rail industry is exploring low carbon alternatives to diesel (GB rail traction diesel consumption of c.500 million litres per annum), with technical demonstrations using hydrogen, and LNG, in addition to the examples cited in the consultation.

4.3

However, due to the lack of certainty around the Government’s commitment to electrification, the fact that rolling stock is a relatively long-lived asset - with a design life of between 30 and 40 years for passenger vehicles, and the absence of a firm strategy for the use of LCFs in rail as a transitional technology, new self-powered vehicles will continue to be specified to use diesel traction in lieu of market ready alternatives.

2/7

5.

QUESTION) Are there specific examples or best practices, the government should take into account when drafting the strategy?

5.1

Nothing specific, but it will be important to fully consult with both the passenger rail and rail freight sectors since their requirements and business models are distinct and will have differing views on the use of LCFs.

Chapter 2 – Demand 6.

QUESTION) Does this chapter accurately capture key trends, opportunities and risks in terms of low carbon fuels demand? If no, please expand on any aspects that you think are missing or inaccurate, or require further exploration.

6.1

On the whole this is a good start, and the chapter does capture the demand trends and the interdependencies between different transport modes. However, the chapter is quite limited in its treatment of the rail sector and would benefit from a more thorough exploration of opportunities and risks to the increased adoption of LCFs in rail.

7.

QUESTION) In your view, what are the key challenges relating to demand in the future transition of the sector?

7.1

Serious consideration needs to be given to, the now likely, scenario where electrification of the rail network does not proceed at the rates established in the TDNS. The slow rollout of electrification will build up a ‘bow wave’ of demand for alternatives to diesel traction as passenger and freight operators seek to achieve net zero.

7.2

Even in a situation where electrification proceeds at pace the programme will continue up to 2050. This means that in any electrification scenario there is a significant opportunity for LCF’s as an interim solution to reduce the carbon emissions of existing diesel rail vehicles.

8.

QUESTION) Apart from developing demand scenarios, are there any other actions the government should consider as part of the strategy development to address uncertainties and identify opportunities on the demand side?

8.1

No response

3/7

9.

QUESTION) For the development of the demand scenarios, are there any key sources of information or data the government should consider?

9.1

The demand scenarios should utilise railway data published by the Office of Rail and Road, the long-term rolling stock strategy and rail demand forecasting data and models held by the Rail Delivery Group and Passenger Demand Forecasting Council. In terms of rail freight, looking beyond the governments rail freight strategy the following could provide an interesting multimodal viewpoint that spans road and rail modes: https://www.networkrailmediacentre.co.uk/news/network-rail-and-highways-englandpublish-first-phase-of-the-solent-to-the-midlands-multimodal-freight-strategy

9.2

The Rail Safety and Standards Board have been carrying out research as part of their DECARB programme to investigate target setting and incentives for reducing carbon emissions in rail.

This work has included looking at incentives such as diesel fuel duty and the Variable Track Access Charge (https://www.rssb.co.uk/en/research-catalogue/CatalogueItem/T1201)

10.

QUESTION) For the development of the demand scenarios, are there any specific aspects that government should consider (e.g. niche uses of low carbon fuels, competing demand from other sectors or technology development) and if so, do you have a view on how best to incorporate them?

10.1 Beyond the examples cited in the document there are other developments within rail to use LCFs other than hydrogen (which is well publicised) and HVO. These include Grand Central’s trial of dual fuel LNG and diesel trains (due to enter passenger service trials in April/May 2022) and the use of bio-LPG in dual fuel configuration on a class 73/9 bi-mode freight locomotive (operated by Colas as part of Network Rail’s maintenance fleet) – due to enter trial service in May/June 2022.

Chapter 3 – Supply 11.

QUESTION) Does this chapter capture key trends, opportunities, and risks in terms of low carbon fuels supply? If no, please expand on any aspects that you think are missing or require further exploration.

11.1 No response 12.

QUESTION) In your view, what are the key challenges and opportunities as relates to supply in the future transition of the sector?

12.1 Supply and distribution will be a key challenge for rail. Typically, trains are refuelled at depots, freight terminals and ports. Refuelling is geographically dispersed, and the installation and commissioning of new refuelling infrastructure could be constrained by existing depot facilities.

4/7

13.

QUESTION) Are there any other actions the government should consider as part of the strategy development to address uncertainties and identify opportunities on the supply side?

13.1 No response 14.

QUESTION) Are there particular actions the government should prioritise as part of the strategy development?

14.1 There is very limited information in the chapter on supply of LCFs to rail because the volumes currently are small. If there is a delay in delivering electrification of the network, as set out in the TDNS, then greater attention will need to be given as to what LCFs could be available to rail given the different priorities for the use of LCFs in other modes e.g., aviation and marine applications.

15.

QUESTION) Do you have any views on how to best capture interdependencies with the global supply chain?

15.1 Please refer to the response under the ‘Summary and General Comments’ section.

Chapter 4 – Industry 16.

QUESTION) Does this chapter capture key trends, opportunities, and risks in terms of UK industry? If no, please expand on any aspects that you think are missing or require further exploration.

16.1 Please refer to points 3.3 and 3.4 in the ‘Summary and General Comments’ section, regarding opportunities for the UK industry to take a lead in LCF technologies for rail.

17.

QUESTION) In your view, what are the key challenges and opportunities for the UK industry in the lead up to 2050?

17.1 No response 18.

QUESTION) What are key actions the government should consider as part of the strategy development to address uncertainties and identify opportunities for UK industry?

18.1 No response

5/7

19.

QUESTION) Are there any production pathways or adaptations to production pathways and infrastructure that are most likely to benefit the UK economy?

19.1 No response 20.

QUESTION) If applicable, how does your organisation plan to adapt to the expected changes in low carbon fuel demand and supply?

20.1 No response Chapter 5 – Policy framework 21.

QUESTION) Does this chapter capture key trends, opportunities, and risks in terms of policy framework? If no, please expand on any aspects that you think are missing or require further exploration.

21.1 Yes 22.

QUESTION) In your view, how should the government best deliver its aims of using LCFs to maximise environmental and economic benefits and are there specific measures the government should take to support the sector’s transition?

22.1 The support provided to decarbonise the rail industry in the UK is tiny compared with other transport modes – recognising the comparatively small contribution to transport greenhouse gas emissions that comes from rail. However, given the slow progress of electrification the government needs to provide targeted support towards decarbonising the rail industry – more than the current level of support through mechanisms like the Innovate UK First of a Kind rail competitions. As stated in paragraph 3.3 there is a market for rail ready LCF technologies in other countries and domestic investment now would enable the UK to develop exportable technologies and knowhow to these markets. Setting firmer domestic targets for decarbonising rail could create the necessary environment to accelerate the required technology developments and investments.

23.

QUESTION) In view of the different challenges and opportunities, are there specific policy measures the government should prioritise and why?

23.1 No response 24.

QUESTION) Are there any key actions the Government should consider as part of the strategy development to identify policy gaps and opportunities?

24.1 No response

6/7

Chapter 6 – Interdependencies 25.

QUESTION) Does this chapter capture key interdependencies and interactions with other policy areas or markets? If no, please expand on any aspects that you think are missing or require further exploration.

25.1 It is understood that other sectors are being prioritised for LCF use. The rail demand is relatively small compared to, for example, aviation but rail should also be prioritised because of the societal benefit of rail decarbonisation. Or if LCFs are not prioritised for rail then alternative solutions need to be sought and prioritised for rail use.

26.

QUESTION) In your view, are there any specific actions the government needs to take as part of the strategy development to address these interactions? If yes, what would those be?

26.1 No response Railway Industry Association April 2022 If you would like further information, please contact RIA Technical Director David Clarke at David.clarke@riagb.org.yk and +44 (0) 20 7201 0777

7/7